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In brief

On Friday, 15 March 2024, the UAE Ministry of Finance (“UAE MoF”) issued a public consultation on the potential framework that the UAE will introduce to implement Pillar 2, the global minimum tax framework. The consultation can be accessed here: The deadline to provide input into the consultation is 10 April 2024.

This consultation will be relevant for all businesses operating in the UAE that are part of a multinational group with global revenue exceeding EUR 750 million. The release of this consultation continues to reaffirm the UAE’s commitment to implementing the Pillar 2 framework (essentially the adoption of a minimum 15% corporate tax rate) although the timeframe for such implementation remains unclear. All businesses impacted by this potential introduction should consider the consultation and provide their views accordingly. With support from our Global Pillar 2 Steering Committee, Baker McKenzie will be considering the consultation in detail and will be happy to support taxpayers with their submissions taking into account the OECD Model Rules, as well as what we have seen other jurisdictions implement across the globe.

The consultation released by the UAE MoF focuses on obtaining views from taxpayers on how the global minimum tax policy could be designed. The consultation itself provides limited views by the UAE MoF as to how such a policy is currently intended to be implemented, however the consultation document itself does note the following key points:

  • The UAE MoF is considering the implementation of the Income Inclusion Rule (“IIR”), the Undertaxed Profits Rule (“UTPR”) and/or a Domestic Minimum Top-Up Tax (“DMTT”) (that could subsequently become a Qualifying DMTT (or “QDMTT”) post peer review) with a focus on interaction with the UAE CT regime and minimizing compliance costs;
  • A proposal not to apply the IIR to smaller UAE headquartered groups (with global revenue below EUR 750 million in line with the OECD Model Rules) to manage compliance costs;
  • Where introduced, a QDMTT would not extend to groups that are below the EUR 750 million threshold, and groups that are domestic (i.e., UAE) only;
  • The Safe Harbour regulations would not be adopted should a QDMTT be introduced;
  • The financial accounting standards that would be used would be IFRS;
  • The UAE MoF is considering the introduction of substance-based incentives, and the questions raised in the consultation focus on understanding how taxpayers benefit from other substance-based incentives around the globe.

Please do contact us for further details on the consultation, and for assistance with drafting any policy reply to the consultation questions.


Reggie Mezu is a Senior Special Counsel in Baker McKenzie’s Dubai office. He focuses on corporate tax and has practiced tax for nearly 30 years, including in the UAE for 15 years. He has multi-jurisdictional and multi-disciplinary professional qualifications in law, accountancy and taxation.


Ben is a senior associate in Habib Al Mulla & Partners, a member firm of Baker & McKenzie International, advising on both international tax and mergers & acquisition matters. Ben has over 10 years experience in the UAE & UK and has advised on matters across the UAE, GCC and globally across this period.

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